Updated September [•], 2021
A User of our Website who is not an Investor may review selected information about the services offered by our Website without revealing his or her identity or providing any Personally Identifiable Information. It is only when a User wishes to become an Investor and participate in the Investor-only accessed portions of the Website and utilize investment tools that a User is required to provide Personally Identifiable Information. Investors who wish to invest in the investment opportunities (“Investment Opportunities”) presented on our Website must provide additional Personally Identifiable Information as described below.
Personally Identifiable Information
Identity Verification Information. Each Investor must provide information designed to verify his or her identity. Such information may include (i) information from a successfully completed electronic check transaction, (ii) a credit report, (iii) tax documents or (iv) other similar information designed to authenticate and confirm your identity and status as an Accredited Investor or a Non-U.S. Person.
Investors must also provide other information sufficient to meet regulatory “suitability” requirements for investing in an Investment Opportunity presented on our Website. Depending on the nature of the offering, this information will include: (i) information concerning an Investor’s net worth and income; (ii) information concerning his or her residency; and (iii) other information we might request to determine whether an Investor qualifies for a particular investment.
In order to make an investment through our Website, an Investor must provide us with certain account and other payment information, such as information needed to make payment via electronic checks, ACH or wire. Our registration process for Investors provides additional details on the types of Payment Information needed.
How We Use Your Personally Identifiable Information
We use your Personally Identifiable Information to process your transactions and facilitate your activities with respect to our Website as set out herein. We do not disclose your Personally Identifiable Information to third parties without your express consent except in the specific circumstances identified in “Third Party Access to Personally Identifiable Information” below.
We will provide Investors with certain materials, including formal notices from regulators, and other information in order to comply with Applicable Law. We will use your Contact Information for these purposes. Where necessary to comply with Applicable Law, we will also use Investor Financial Information for these purposes. Investors cannot opt-out of this use of information.
We use the Personally Identifiable Information you provide to process transactions that you have authorized us to undertake and to provide you with the Services you have requested. Investors cannot opt-out of this use of information.
In order to communicate with you and to confirm (where necessary) whether you are eligible for a transaction, we will rely on an Investor’s Contact Information and, where applicable, on his or her Investor Financial Information.
We use your Personally Identifiable Information in the operation of our Website and to comply with Applicable Law. You cannot participate in our Website if you seek to opt-out of these uses of your Information.
Periodically, we may send you materials for informational purposes, such as notices of investment opportunities through our Website. Such informal information may take a range of forms, including email, newsletters, or automatic notices generated by our Website. You are entitled to opt-out from receiving this informal information. Periodically, we may choose to send news, bulletins, marketing materials, or other information to Investors, and will use Personally Identifiable Information to send such communications. If we choose to undertake such communications, you will have the ability to opt-out of receiving these communications.
Our Users may provide feedback to us about our Website and our Services. You are free to choose whether you participate in these activities. We may ask that, in addition to providing your responses, you also provide Contact Information. In these instances, we use any Personally Identifiable Information you choose provide to us in connection with these activities strictly for the purposes for which you submit the information. We will provide Investors with certain materials, including formal notices from regulators, and other information in order to comply with Applicable Law. We will use your Contact Information for these purposes. Where necessary to comply with Applicable Law, we will also use Investor Financial Information for these purposes. Investors cannot opt-out of this use of information.
How We Protect Your Personally Identifiable Information
We have security systems in place designed to prevent unauthorized access to or disclosure of Personally Identifiable Information, and we take all reasonable steps to secure and safeguard this Information, including:
- Our Website’s password-protected section requires Users to give us unique identifiers such as their user name and password;
- We employ a secure channel using Secure Sockets Layer encryption to protect information exchanged over the Internet between your web browser and our servers;
- We provide access to our databases containing Personally Identifiable Information on a need-to-know basis only; and
- We use automated tools to monitor network traffic to identify unauthorized attempts to upload information, change information or otherwise seek to “hack into” our systems.
- We recognize the sensitivity of information provided in response to our Investor Qualifying Questions and take the following additional precautions with respect to such information:
- We store investor questionnaire information that we receive on a secure system isolated from direct connection to the Internet.
- We encrypt investor questionnaire Information (including account and social security number information) using the same encryption standard used by banks to secure sensitive customer data.
Our security systems are structured to deter and prevent hackers and others from accessing information you provide to us. We make no warranty that our security systems are fail proof. Due to the nature of Internet communications and evolving technologies, we cannot provide and we disclaim assurance that the information you provide us will remain free from loss, misuse, or alteration by third parties who, despite our efforts, obtain unauthorized access.
Changing or Removing Information; Opting Out
Applicable Law places certain obligations on Investors to keep information current, including, for example, Form W-9 Information. It is particularly important for you to keep your Investor Financial Information current and to report to us any material change in this Information. We use this information to provide you with investment opportunities and financial distributions due to you as an equity owner of an Investment Opportunity in which you have invested through our Website. Without current information, you receive information in error or that you are not eligible to receive or act on. To allow appropriate control over Personally Identifiable Information, you can access your account (after supplying your user name and password) to change or update discretionary information that you have previously submitted. You are entitled to decline to participate in certain Services and to decline to give us permission (or to revoke that permission in your discretion) to use your Personally Identifiable Information for certain purposes. We provide you with the ability to opt-out of receiving communications concerning, or being included in, these activities. To opt-out of Services for which an opt-out right is available, please email us at email@example.com. We can also answer questions or assist if you contact us as provided herein. You will not be allowed to opt–out of required notices or other legal and related notices concerning your relationship to the Website. If you request, we will remove your name and all other Personally Identifiable Information from our databases. It may be impossible to remove this information completely, due to IRS and regulatory reporting requirements, ownership in a Investment Opportunity in which you have invested through our Website and the rights thereof, data backups and records of deletions. If you request deletion of your information, you will be unable to use certain features of the Website and any associated Services. You may not remove de-identified, anonymous, or aggregate data from our databases.
Third Party Access to Personally Identifiable Information
Anonymous, Aggregate Information
Anonymous Information Linked With Your Personally Identifiable Information Is Protected As “Personally Identifiable Information”
Notice of Security Incident
If we detect, despite the safeguards set out above, an intrusion or other unauthorized access to or use of Personally Identifiable Information, we will (i) notify affected Users of the intrusion if we determine that the information at issue is sensitive; (ii) deliver this notice by the means we deem most efficient under the circumstances (such as, for example, first class mail or email); (iii) use contact information for each affected User in our files; and (iv) use commercially reasonable efforts to accomplish these steps and effect this notice in a timely manner. To the extent Applicable Law requires steps in addition to those specified above, we will under all circumstances comply with Applicable Law.
Participation by Minors
Due to federal law (as reflected in the Children’s Online Privacy Protection Act), WE DO NOT ALLOW INDIVIDUALS WHO WE KNOW ARE UNDER 18 TO PARTICIPATE IN OUR WEBSITE OR SERVICES. YOU MUST BE AT LEAST 18 YEARS OLD TO USE OUR WEBSITE AND SERVICES.
Notification of Changes
Privacy Rights of California Residents
California law requires that we provide you with a summary of your privacy rights under the California Online Privacy Protection Act (the “Act”) and the California Business and Professions Code. As required by the Act, we will provide you with the categories of Personally Identifiable Information that we collect through the Website and the categories of third parties with whom such Personally Identifiable Information may be shared for direct marketing purposes at your request. California law requires us to inform you, at your request, (1) the categories of Personally Identifiable Information we collect and what third parties we share that information with; (2) the names and addresses of those third parties; and (3) examples of the products marketed by those companies. The Act further requires us to allow you to control who you do not want us to share that information with. To obtain this information, please send a request by email or standard mail to the address set out herein. When contacting us, please indicate your name, address, email address, and what Personally Identifiable Information you do not want us to share with affiliated businesses or marketing partners. The request should be labeled “California Customer Choice Notice.” Please allow 30 days for a response. There is no charge for controlling the sharing of your Personally Identifiable Information or requesting this notice.
Complaints to Regulators
If you are a California resident, you may report complaints to the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs by contacting them in writing at 400 R Street, Sacramento, CA 95814, or by telephone at (800) 952-5210. Other States may provide similar avenues for lodging complaints. Please check with your State’s consumer protection authority.
List of cookies we collect
The table below lists the cookies we collect and what information they store.
|COOKIE name||COOKIE Description|
|CART||The association with your shopping cart.|
|CATEGORY_INFO||Stores the category info on the page, that allows to display pages more quickly.|
|COMPARE||The items that you have in the Compare Products list.|
|CURRENCY||Your preferred currency|
|CUSTOMER||An encrypted version of your customer id with the store.|
|CUSTOMER_AUTH||An indicator if you are currently logged into the store.|
|CUSTOMER_INFO||An encrypted version of the customer group you belong to.|
|CUSTOMER_SEGMENT_IDS||Stores the Customer Segment ID|
|EXTERNAL_NO_CACHE||A flag, which indicates whether caching is disabled or not.|
|FRONTEND||You session ID on the server.|
|GUEST-VIEW||Allows guests to edit their orders.|
|LAST_CATEGORY||The last category you visited.|
|LAST_PRODUCT||The most recent product you have viewed.|
|NEWMESSAGE||Indicates whether a new message has been received.|
|NO_CACHE||Indicates whether it is allowed to use cache.|
|PERSISTENT_SHOPPING_CART||A link to information about your cart and viewing history if you have asked the Website.|
|POLL||The ID of any polls you have recently voted in.|
|POLLN||Information on what polls you have voted on.|
|RECENTLYCOMPARED||The items that you have recently compared.|
|STF||Information on products you have emailed to friends.|
|STORE||The store view or language you have selected.|
|VIEWED_PRODUCT_IDS||The products that you have recently viewed.|
firstname.lastname@example.org, or send mail to:
2255 S. Wadsworth Boulevard, Suite 106
Lakewood, CO 80227
For Investors in the European Union
You have the right to access information held about you. Any access request may be subject to a fee of $10 to meet our costs in providing you with details of the information we hold about you. If you wish to exercise this right, please contact us at email@example.com.